Professional Documents
Culture Documents
Clark v. Rameker
Clark v. Rameker
Syllabus
Syllabus
Syllabus
No. 13–299
_________________
federal law, see §522(b)(2), or state law, see §522(b)(3). Both tracks
permit debtors to exempt “retirement funds.” See §522(b)(3)(C) (re
tirement funds exemption for debtors proceeding under state law);
§522(d)(12) (identical exemption for debtors proceeding under federal
law). Petitioners elected to proceed under state law, so we refer to
§522(b)(3)(C) throughout.
Cite as: 573 U. S. ____ (2014) 3
as an inherited account.
Inherited IRAs do not operate like ordinary IRAs. Un
like with a traditional or Roth IRA, an individual may
withdraw funds from an inherited IRA at any time, with
out paying a tax penalty. §72(t)(2)(A)(ii). Indeed, the
owner of an inherited IRA not only may but must with
draw its funds: The owner must either withdraw the
entire balance in the account within five years of the
original owner’s death or take minimum distributions on
an annual basis. See §§408(a)(6), 401(a)(9)(B); 26 CFR
§1.408–8 (2013) (Q–1 and A–1(a) incorporating
§1.401(a)(9)–3 (Q–1 and A–1(a))); see generally D. Car
tano, Taxation of Individual Retirement Accounts
§32.02[A] (2013). And unlike with a traditional or Roth
IRA, the owner of an inherited IRA may never make con
tributions to the account. 26 U. S. C. §219(d)(4).
B
In 2000, Ruth Heffron established a traditional IRA and
named her daughter, Heidi Heffron-Clark, as the sole
beneficiary of the account. When Ms. Heffron died in
2001, her IRA—which was then worth just over
$450,000—passed to her daughter and became an inherited
IRA. Ms. Heffron-Clark elected to take monthly distri
butions from the account.
In October 2010, Ms. Heffron-Clark and her husband,
petitioners in this Court, filed a Chapter 7 bankruptcy
petition. They identified the inherited IRA, by then worth
roughly $300,000, as exempt from the bankruptcy estate
under 11 U. S. C. §522(b)(3)(C). Respondents, the bank
ruptcy trustee and unsecured creditors of the estate, ob
jected to the claimed exemption on the ground that the
funds in the inherited IRA were not “retirement funds”
within the meaning of the statute.
The Bankruptcy Court agreed, disallowing the exemp
tion. In re Clark, 450 B. R. 858, 866 (WD Wisc. 2011).
4 CLARK v. RAMEKER
III
Although petitioners’ counterarguments are not without
force, they do not overcome the statute’s text and purpose.
Petitioners’ primary argument is that funds in an inher
ited IRA are retirement funds because—regardless of
whether they currently sit in an account bearing the legal
characteristics of a fund set aside for retirement—they did
so at an earlier moment in time. After all, petitioners
point out, “the initial owner” of the account “set aside the
funds in question for retirement by depositing them in a”
traditional or Roth IRA. Brief for Petitioners 21. And
“[t]he [initial] owner’s death does not in any way affect the
funds in the account.” Ibid.
We disagree. In ordinary usage, to speak of a person’s
“retirement funds” implies that the funds are currently in
an account set aside for retirement, not that they were set
aside for that purpose at some prior date by an entirely
different person. Under petitioners’ contrary logic, if an
individual withdraws money from a traditional IRA and
gives it to a friend who then deposits it into a checking
account, that money should be forever deemed “retirement
funds” because it was originally set aside for retirement.
That is plainly incorrect.
More fundamentally, the backward-looking inquiry
urged by petitioners would render a substantial portion of
11 U. S. C. §522(b)(3)(C)’s text superfluous. The funds
contained in every individual-held account exempt from
taxation under the Tax Code provisions enumerated in
§522(b)(3)(C) have been, at some point in time, “retirement
funds.” So on petitioners’ view, rather than defining the
exemption to cover “retirement funds to the extent that
those funds are in a fund or account that is exempt from
taxation under [the enumerated sections] of the Internal
Revenue Code,” Congress could have achieved the exact
same result through a provision covering any “fund or
account that is exempt from taxation under [the enumer
Cite as: 573 U. S. ____ (2014) 9
——————
4 Petitioners also argue that inherited IRAs are similar enough to